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SDSBS Teams Up To Win Landmark Victory
n May 18, 2005, a jury in West Palm Beach, Florida
delivered an historic judgment of almost $1.45 billion
against Morgan Stanley & Co. on behalf of financier
Ronald O. Perelman’s company, Coleman (Parent)
Holdings, Inc. The jury found the investment banker li-
able for its role in a fraud relating to the 1998 sale of
Coleman Company to Sunbeam Corporation. Reportedly,
it is the largest judgment ever returned in the U.S. for
the benefit of a single individual. The case was marked
by the defendant’s efforts to evade obligations to pro-
duce evidence and its accusations of improper conduct
against everyone from the judge to its own lawyers.
It was a David vs. Goliath battle. Mr. Perelman’s David,
however, had the determination and resources necessary
to pursue Morgan’s Goliath. The battle took place before
Palm Beach County Circuit Court Judge Elizabeth T. Maass,
who frequently found herself and the integrity of the legal
system challenged by Morgan’s aggressive defense.
In December 1997, Mr. Perelman, with controlling interest
in Coleman, was approached by Sunbeam with an offer to
buy Coleman. No agreement was reached. Morgan then
contacted Mr. Perelman on behalf of Sunbeam, and nego-
tiated the sale. The sale was completed in March 1998,
netting Mr. Perelman $1.5 billion, $680 million of which
was in Sunbeam stock. Morgan’s fee was $10 million.
Weeks later, Sunbeam’s market value dropped. New
sales and earnings figures conflicted with earlier state-
ments backed by Morgan. Sunbeam’s accountant, Arthur
Andersen, withdrew an audit of the company’s books.
In 2001, Sunbeam filed for bankruptcy and its share-
holders were left with
worthless stock. Mr.
Perelman focused onAndersen’s role in
Sunbeam’s demise.
During the Andersen
litigation, Mr. Perelman’slegal team discovered a
letter from Andersen to
Morgan dated days beforethe Coleman-Sunbeam
sale closed. It outlined
Sunbeam’s decreasingsales, escalating debts,
and accumulating losses.
Nonetheless, Sunbeamissued a press release,
drafted with Morgan’s
approval, that presentedSunbeam’s economic per-
formance as optimistic,
concealing the true facts.
Charged by Mr. Perelman
with fraud for its part in
the cover-up, Morgan argued that it had accuratelyreported all of the information available to it at the time,
and that it, too, was being lied to by Sunbeam. However,
Morgan not only knew of Sunbeam’s financial difficulties,but had participated in concealing them. In May 2003,
Mr. Perelman sued Morgan.
Jerold Solovy, of Jenner & Block, was the primary litigator
for Mr. Perelman. Mr. Solovy had successfully partneredwith Jack Scarola, of Searcy Denney Scarola Barnhart &
Shipley, for a $70 million Continued on page two.
Perelman: $1.58 BillionMorgan Stanley: O
A quarterly reportto clients
and attorneys.
VOLUME 05NUMBER 3
SEARCY DENNEY SCAROLA BARNHART & SHIPLEY P.A.
2 OF COUNSEL NEWSLETTER VOLUME 05 NUMBER 3
ATTORNEYS AT LAW:
ROSALYN SIA BAKER-BARNESF. GREGORY BARNHART
LAWRENCE J. BLOCK, JR.EARL L. DENNEY, JR.SEAN C. DOMNICK
JAMES W. GUSTAFSON, JR.JACK P. HILL
DAVID K. KELLEY, JR.WILLIAM B. KINGDARRYL L. LEWIS
WILLIAM A. NORTONDAVID J. SALESJACK SCAROLA
CHRISTIAN D. SEARCYHARRY A. SHEVINJOHN A. SHIPLEY
CHRISTOPHER K. SPEEDKAREN E. TERRY
C. CALVIN WARRINER IIIDAVID J. WHITE
PARALEGALS:
VIVIAN AYAN-TEJEDALAURIE J. BRIGGSDEANE L. CADY
DANIEL J. CALLOWAYEMILIO DIAMANTISRANDY M. DUFRESNEDAVID W. GILMORE
TED E. KULESAVINCENT LEONARD
J. PETER LOVECHRISTOPHER J. PILATO
ROBERT W. PITCHERKATHLEEN SIMONSTEVE M. SMITHBONNIE STARKWALTER STEIN
BRIAN P. SULLIVANKEVIN J. WALSHMELANIE WEESE
MANAGER: JOAN WILLIAMS
ASSOCIATE EDITOR: ROBIN KRIBERNEY
CREATIVE DIRECTOR: DE CARTERBROWN
NOTE: The accounts of recent trials, verdicts and settle-ments contained in this newsletter are intended to illus-trate the experience of the firm in a variety of litigationareas. Each case is unique, and the results in one casedo not necessarily indicate the quality or value of anyother case. Omitting clients’ names and/or defen-dants’ names are the result of requests for anonymity.
2139 PALM BEACH LAKES BOULEVARDWEST PALM BEACH, FLORIDA 33409
TOLL FREE: 800-780-8607 • LOCAL: 561-686-6300FAX: 561-478-0754
THE TOWLE HOUSE, 517 NORTH CALHOUN STREETTALLAHASSEE, FLORIDA 32301
TOLL FREE: 888-549-7011 • LOCAL: 850-224-7600FAX: 850-224-7602
■
■
Jack Scarola(Continued from page one.)
SDSBS Wins$1.58 Billion VerdictAgainst Morgan StanleyFinancial Services Firm
- - Excerpt fromJack Scarola’s
closing argument
Justice is most often depicted in art as a
woman. She is blindfolded. In one hand
she holds scales, and in the other hand asword. The reason for the blindfold is
because justice is, indeed, blind to power,
position, wealth, religion, national origin.Those things do not matter.
The scale is there so that equity and justice
may be accurately weighed. And when thescale is placed out of balance, when it is
tipped in a way that results in injustice,
that strong and powerful woman isprepared to use her sword in order to
restore the balance, in order to make
certain that the scales are not tippedunfairly again. Each of you,
no matter what your gender may be,
have your hand on that sword.It is an awesome responsibility.
It is a tremendous power that you have.
“
”EDITORS: DIANE TRUMAN AND PAULINE MUELLER
settlement on the case against Andersen. Jack Scarola was asked to partner on the
case against Morgan.
During discovery, Morgan engaged in a concerted effort to delay and obstruct the
litigation. It failed to produce court-ordered documents, destroyed evidence, and
falsely certified that it had disclosed other documents.
Confronted with Morgan’s misconduct, Judge Maass opted for sanctions against
Morgan, directed at correcting the misconduct rather than punishment. Morgan
continued to evade court orders, charging the judge with bias and emotionalism.
The Court escalated sanctions against Morgan.
In March 2005, Judge Maass concluded that the abuses by
Morgan during discovery had come to “infect the entire case”.
She directed the jury to accept as fact that Morgan had
conspired with and assisted Sunbeam in perpetrating a fraud.
As the Court summarized its findings, “[D]iscovery abuses and
misrepresentations by Morgan Stanley . . . would take a
volume to recite.” The plaintiff no longer had the burden to
show that fraudulent behavior occurred, but only to show that
Mr. Perelman had relied on false information from Sunbeam/
Morgan and had suffered damage as a result.
Morgan tried to have Judge Maass removed from the case,
arguing that she had “bias, antagonism, and hostility” toward
the company. Morgan’s motion was denied by Judge Maass
and by the appellate court. On May 16, the jury awarded Mr.
Perelman $604 million in compensatory damages for having
relied on Morgan’s misrepresentations. Two days later, the jury
awarded Mr. Perelman $850 million in punitive damages. And
a month later, the trial judge added millions in interest owed
by Morgan Stanley to Ronald Perelman. The judgment now
totals $1.58 billion. Morgan said it plans to appeal the verdict.
Lawyers representing Mr. Perelman’s company, Coleman
(Parent) Holdings, Inc., intend to pursue contempt sanctions
against Morgan, including millions of dollars in attorneys’
fees and costs. Federal regulatory and enforcement agencies
have focused on the disclosures made in this case. Morgan’s
current CEO, Philip Purcell, recently announced his resignation
following the earlier departure of several other Morgan exec-
utives. The very future of Morgan Stanley, a Wall Street giant,
is in question.
Morgan’s Goliath may not be dead, but Ronald Perelman has
certainly brought this Goliath to its knees. ■
WEBSITE: www.searcylaw.com
■
SEARCY DENNEY SCAROLA BARNHART & SHIPLEY, PA 3 OF COUNSEL NEWSLETTER VOLUME 05 NUMBER 3
n May 15, 2000, fifty-year-old Irma Imelda Carter was
found slumped over her bed by her 22-year-old son,
Stephen, and 16-year-old daughter, Lauri. Stephen attempted
cardiopulmonary resuscitation, but was unsuccessful in reviv-
ing his mother. The fire-rescue paramedics arrived in re-
sponse to the 911 call, and they, too, attempted to revive
Irma as Stephen and Lauri watched in horror. Their efforts
were futile as well. Moments later,
Stephen had to call his father, out of
town on business, and tell him that,
tragically, his wife of thirty-three years
was dead.
The Carter family requested an autopsy
to determine the cause of death. The
report stated that she had died of con-
gestive heart failure. In the two weeks
before she died, Irma had been under
the care of Dr. Agustin Sanz, an inter-
nist, but there had been no indications
from the doctor of any problem that
would have resulted in her abrupt de-
mise. Stephen requested copies of his
mother’s medical records from Dr.
Sanz, and the family was shocked at
what the records revealed.
Irma Carter had an overactive thyroid,
a condition that can result in the de-
velopment of congestive heart failure.
She had been referred to Dr. Sanz by Dr. Tania Serrano, an
obstetrician/gynecologist who had recently placed Irma on
hormone replacement therapy. When Dr. Sanz first saw
Irma on May 1, 2000, he documented a completely normal
physical examination. He noted the test results indicating
an overactive thyroid and an elevated liver function, but
specifically stated that she had no chest pain, no swelling,
and that the palpitations of which she complained occurred
only upon lying down at night.
Stephen, however, had been present in the examination
room for the May 1 of fice visit, and specifically recalled his
mother telling Dr. Sanz that she was experiencing shortness
of breath, and feeling weak and tired. Stephen had explained
to Dr. Sanz that his mother continued to have swelling of her
legs and ankles. In fact, he actually raised her leg upwards
and pressed on it, showing that the swelling was so severe
that when he pressed on the legs and ankles, his finger left an
indentation. In addition to other symptoms he described to
Dr. Sanz, Stephen pointed out that he could see a vein in his
mother’s neck pulsating. Dr. Sanz did not record any of these
findings; his report appeared as if Irma Carter’s examination
revealed nothing out of the norm.
On May 10, 2000, Irma underwent two tests ordered by Dr.
Sanz – an abdominal ultrasound and a
24-hour Holter monitor. The abdominal
ultrasound revealed fluid in the abdomi-
nal cavity, a sign of a serious problem
including the possibility of heart dis-
ease. The Holter monitor’s results were
also alarming. Between May 10 and
11, Irma’s heart rate was over 220
beats per minute for the entire study.
Because Dr. Sanz never requested the
results of the Holter monitor study, they
were not reported to him until after
Irma’s death.
On May 12, Irma was still feeling very
sick and she returned to Dr. Sanz’ of-
fice. Dr. Sanz by this time had the ul-
trasound report of fluid in the abdo-
men. He noted a soft and non-tender
abdomen in his examination of Irma,
but also included in his examination
notes that Irma’s heart, pulse, and res-
piratory rate was normal, despite the fact that she had re-
corded an extraordinarily high pulse and respiratory rate
during the 24 hours under the monitor. Dr. Sanz sent Irma
home, and three days later she died.
After reviewing the medical records and autopsy report, the
Carter family hired attorneys Darryl Lewis, Sia Baker-Barnes, and
Jack Hill, with Searcy Denney Scarola Barnhart & Shipley, to pur-
sue charges of medical negligence. The trial began on February
28, 2005, and lasted three weeks. Throughout the trial, the
SDSBS team worked hard to disprove Dr. Sanz’ records using tes-
timony of family members, admissions in Irma Carter’s email cor-
respondence where she had described her symptoms, and most
importantly, the fact that it was nearly impossible, medically, for
Irma to appear as described by Dr. Sanz.
The defense argued vehemently that Dr. Sanz’ records indi-
cated a normal patient, that Continued on page four.
Ignored Symptoms Cause Woman’s DeathIGNORED SYMPTOMSRESULT IN MEDICALNEGLIGENCE VERDICTAGAINST DOCTOR
$3.4 MillionVerdict:
O
4 OF COUNSEL NEWSLETTER VOLUME 05 NUMBER 3
The Meeting Corner:
Continued from page three.
the family members were not telling the truth, and that Irma
Carter herself held back her symptoms from Dr. Sanz. Experts for
the defense claimed that Dr. Sanz had no reason to suspect any
heart problem and, according to defense’s pathology expert, the
medical evidence was consistent with Irma Carter developing
congestive heart failure in the three days after she last saw Dr.
Sanz. Defense also attempted to blame family members by sug-
gesting that if her condition was as bad as they described, they
would have, and should have, taken her to the hospital.
Plaintiffs’ attorneys were able to successfully demonstrate that Dr.
Sanz’ records did not accurately reflect Irma Carter’s true symptoms;
that the test results would have been available to Dr. Sanz if he had
requested them; and that if Irma Carter had been timely diagnosed
and treated, she would likely have survived to live out her normal
life. The jury deliberated only four hours before reaching a verdict in
favor of the Plaintiffs. The jury specifically found that Dr. Sanz was
negligent in his treatment of Irma Carter, and that his negligence
caused her death. After assigning 100% responsibility to Dr. Sanz,
the jury awarded the family approximately $3.4 million in dam-
ages. In addition to awarding compensation for the loss of the
central member of the Carter family, the jury provided the family
with the long-awaited justice they deserved. ■
Many Ignored SymptomsCause Woman’s Death
Senator Bill Nelson HonoredAt Breakfast by SDSBS
(l-r) John Shipley, Earl Denney, Senator Bill Nelson,
Karen Terry, Bill Norton, and David Kelley.
On March 21, 2005 SDSBS hosted a breakfast for Senator Bill
Nelson at the Governors Club in West Palm Beach. ■
Randy M. DufresneRANDY M. DUFRESNE grew up in Northern Michi-
gan. He attended the University of South Florida,
receiving a Bachelor of Arts degree in Finance in
1977. While working for Aetna, Travelers, and Reli-
ance Insurance Company over the past 23 years, he
gained an extensive background in all areas of the
insurance industry. He was engaged in all aspects
of the claims industry ranging from claims adjusting
to claims management. Randy joined Searcy
Denney Scarola Barnhart & Shipley in 2004. Work-
ing primarily with Harry Shevin, Randy’s experience
includes personal injury, contract, wrongful death,
latent construction defect, medical malpractice,
nursing home, and product liability claims. ■
SEARCY DENNEY SCAROLA BARNHART & SHIPLEY, PA
Log onto...
www.searcylaw.com
...for the latest newsand information aboutSearcy Denney ScarolaBarnhart & Shipley
SEARCY DENNEY SCAROLA BARNHART & SHIPLEY, PA 5 OF COUNSEL NEWSLETTER VOLUME 05 NUMBER 3
Failure by Doctor and Hospital to Provide ProperEvaluation Results in Coma for Young Girl
mediately called 911 and an emergency crew rushed
her daughter back to Defendant Hospital. Juliette
never regained consciousness. A blockage in her shunthad caused a dangerous increase in the intracranial
pressure, causing severe brain damage.
Twelve-year-old Juliette remains, at
present, in a minimally conscious
state. She has sleep/wake cycles and
responds to stimulations, but does
not communicate or interact with
those around her. She requires 24-
hour care, totally dependent on her
family and outside caregivers. She will
require pulmonary follow-up and pos-
sibly a tracheotomy and gastrostomy
revisions for the remainder of her life.
In order to care for her, her family will
need a completely accessible home,
including LPN/RN nursing care.
The family contacted attorney Christo-
pher K. Speed, of Searcy Denney Scarola Barnhart &
Shipley, who set up a ‘special needs trust’ for Juliette. The
trust qualified Juliette for Medicaid benefits, which would
otherwise not be available to her. Juliette’s guardian re-
tained special counsel, Scott M. Solkoff, to draft the docu-
ments. In reviewing the evidence, Mr. Speed established
that Defendant Hospital staff had failed to provide full and
appropriate surveillance, monitoring, and
neurologic evaluation of Juliette’s condi-
tion. The hospital and its staf f also failed
to provide appropriate neurosurgical
intervention to prevent the coma that
Juliette will suf fer for the remainder of
her life. An action was brought on be-
half of Juliette, charging the hospital
with medical negligence.
Following extensive negotiations, Chris Speed was able
to obtain a settlement between the J family and the
hospital for $7.5 million. A separate settlement had
previously been made with the neurosurgeon for
$250,000, his insurance policy limits. This money will
be placed in Juliette’s trust to provide her with optimal
care for the rest of her life. ■
“She is in aminimally
conscious state,requiring 24-hour care,pulmonary follow-up
and surgical revisions forthe remainder
of her life.”
NEGLIGENCEFROM FAILURE TOPROVIDE PROPERMEDICAL CARE
$7.5 MillionSettlement:
A t 12 years of age, Juliette J was a young girl with
more than her share of life’s dif ficult circumstances.
At the age of two, she had contracted spinal meningitis,
leaving her dependent upon a shunt placed in her brain
to drain excess cerebral spinal fluid down into her
stomach. The shunt enabled her to
reduce intracranial pressure brought
about by a build-up of the spinal
fluid. Ten years later, Juliette’s pedi-
atric neurosurgeon, Dr. C, examined
her and found that the original shunt
was now too short. He recom-
mended replacing it.
On May 31, 2000, Juliette was admit-
ted to Defendant Hospital for shunt
replacement. The procedure ap-
peared to be successful, it functioned
properly, and Juliette was discharged
to go home the next day, June 1.
Five days later, Juliette’s family noticed
she was not responding normally, and was lethargic – not
the usual behavior for a young and active girl. Around 8:30
pm on June 6th, Kathleen J, Juliette’s mother, became
alarmed and took Juliette to the emergency room at De-
fendant Hospital where Juliette was examined and tested.
Around midnight, Dr. C, responding to the hospital’s call,
determined that a tap was needed to clear potential block-
age in the newly replaced shunt. According to Dr. C, a
blockage was causing her symptoms, and, if left in place,
could lead to serious brain injury.
Dr. C performed the tap procedure and determined that
Juliette’s condition had immediately improved. He left
the hospital shortly after, leaving Juliette’s care in the
hands of the emergency room physician, Dr. L. Juliette
remained in the emergency room for over an hour, and
about 3:00 am the next morning, was discharged to go
home with her mother. No further instructions were
given to the family for Juliette’s care, or for conditions
that must be monitored.
The exhausted family went to bed after returning
home, and awoke at 8:00 am. When they checked on
Juliette, she was totally unresponsive. Kathleen J im-
A
6 OF COUNSEL NEWSLETTER VOLUME 05 NUMBER 3SEARCY DENNEY SCAROLA BARNHART & SHIPLEY, PA
ugust 12, 2000, was a typical summer day in Jack-
sonville, Florida. A heavy rainstorm had dumped a large
amount of water on the northeast part of the state. At
the east end of the Hart Bridge Expressway in Jackson-
ville, the accumulation of rain created a huge, shallow
lake – 281 feet long and one foot deep. The monster
puddle covered the entire left through-lane. A car be-
longing to WTLV-TV (Multimedia Holdings), driven by a
Mr. Doug Lockwood, came east-bound over the bridge
and directly into the water. The car skidded out of control
and slammed into the retaining wall. Another vehicle,
driven by a Ms. Shana Williams, came over the bridge
right behind Mr. Lockwood’s vehicle and it, too, hit the
water, skidded, and slammed into the retaining wall.
Both drivers pulled their cars over to a stripe-marked
area on the roadway, to the right of the through-lanes
and near the Atlantic Avenue exit of the Hart Bridge.
The Jacksonville Sherif f’s Office responded to the two
accidents. As the deputy talked with Lockwood and
Williams, a third vehicle, driven by Mr. Jason Keiffer,
came over the bridge. Like the first two vehicles, Mr.
Keif fer’s car hit the lake and skidded out of control,
still in the through-lane.
Behind Mr. Keif fer’s vehicle was a large gasoline
tanker-truck driven by Christian Darby Stephenson,
coming over the Hart Bridge directly towards the lake
Lack of Road Maintenance and SafetyProcedures Results in Deadly Crash
and the accident scenes spread before him. The truck
driver, a 29-year-old married father with a young
daughter and a son on the way, immediately realized
that he had three very hard choices to make as his
truck came toward the scene: he could continue
straight ahead in the through-lane and plow over Mr.
Keif fer’s vehicle; he could avoid Mr. Keif fer by mov-
ing toward the area where Lockwood, Williams and
the Sherif f’s deputy waited with their vehicles; or
he could try to make a hard right onto the Atlantic
Avenue exit, avoiding the other vehicles but placing
himself in great danger. Christian Stephenson hero-
ically chose option three. Tragically, in attempting
the tight turn, the tanker jackknifed, struck the guard
rail, overturned and exploded, killing Christian. He is
survived by his wife Amie, and their two children,
Hailey and Christian, Jr.
In the aftermath of the accident, Amie brought a
wrongful death action against the Florida Department
of Transportation (FDOT) for its failure to maintain the
road at the accident site so that rain water would have
drained properly, for its failure to warn drivers of the dan-
gerous condition, and for its failure to remedy the dan-
gerous condition. The Stephenson family was repre-
sented by attorneys Chris Searcy, Sean Domnick and
Lance Block of Searcy Denney Scarola Barnhart & Shipley,
and co-counsel Howard C. Coker of Jacksonville.
FDOT is responsible for the maintenance and safety of
Florida’s roads and highways. Evidence in the case
showed that FDOT failed to maintain the roadway drains
on a regular basis. During the ensuing investigation of
the series of accidents, it was revealed that the cause of
the standing water at the base of Hart Bridge was a drain
clogged by a vehicle’s mud flap or similar large piece of
plastic lodged in the drainage system. The mud flap/
plastic mysteriously disappeared after FDOT took cus-
tody of it following the investigation. Despite the loss of
this crucial piece of evidence, the Duval County Circuit
Court issued a final judgment in April 2005 for Amie and
the children in the amount of $1.3 million. ■
FAILURE TOMAINTAIN SAFEROAD CONDITIONSRESULTS IN$1.3 MILLION VERDICTAGAINST FDOT
$1.3 MillionVerdict:
Failure By Medical Experts to DetectMassive Aneurysm Results In Death n June 3, 1998, Alan R, a 55-year-old recently-
retired VA hospital administrator, awoke at 3:00
a.m. with acute onset of back pain so severe he im-
mediately went to the emergency room. He was
discharged from the ER within one hour of his arrival,
and sent home with a prescription for painkillers and
muscle relaxants. The back pain persisted that morn-
ing, and Mr. R went to his primary care physician.
Once again, he was sent home with painkillers and
muscle relaxants. Two days later, Mr. R called 911
from home and was transferred by ambulance back
to the same hospital, where he was diagnosed with
a ruptured abdominal aortic aneurysm (AAA). The
aneurysm had been the cause of the persistent severe
back pain, and was missed by both physicians. The
aneurysm was the size of two regulation softballs.
When Mr. R initially went to the emergency room of
the hospital, the ER physician’s working diagnosis
was (1) musculoskeletal back pain, or (2) AAA. De-
spite the life-threatening nature of AAA, the ER
physician did no diagnostic studies to rule out AAA.
Instead, the ER physician concluded that Mr. R’s back
pain was probably musculoskeletal in nature. He
prescribed injections of painkillers and muscle relax-
ants, and discharged Mr. R home, less than one hour
after Mr. R’s arrival at the ER.
Mr. R’s severe back pain persisted, unrelieved, despite
the prescription medications from the ER. Mr. R called
his family doctor and asked for an appointment. Like
the ER physician, Mr. R’s family doctor ordered no
diagnostic studies, not even an abdominal examina-
tion. Mr. R’s wife, who was present at her husband’s
visits to the hospital and to the family physician, testi-
fied that the family physician “never laid a hand on my
husband.” The family doctor concluded that Mr. R’s
back pain was due to musculoskeletal problems, and
he sent Mr. R home with prescriptions for narcotic
pain relievers, muscle relaxants, and steroids. Mr. R
was instructed to return to the family physician if he
did not improve in three days.
Two days later, at approximately 9:00 a.m., paramedics
responded to Mr. R’s 911 call for help. The paramed-
ics documented a pulsatile abdominal mass, stating in
their records “suspected AAA”. They immediately
transported him to the hospital. Upon arrival, Mr. R
was in shock from loss of blood due to the ruptured
aneurysm. An ultrasound before emergency surgery
showed an aneurysm the size of two regulation soft-
balls. Mr. R’s blood loss due to the ruptured aneu-
rysm was so massive that dur-
ing surgery he required the
transfusion of two and one-
half times the total blood vol-
ume in his body.
Unable to withstand the mas-
sive blood loss, and preop-
erative shock, Mr. R went
into cardiac arrest and died
immediately after the surgery
was completed.
Mr. R had a 35-inch waist. All of
the experts, both plaintiff and
defense, agreed that the aneurysm found in Mr. R, and
documented by the hospital’s radiologist, was massive.
In addition, all experts testified that the aneurysm was
the same size when Mr. R initially presented himself to
the hospital, as it was two days later, when he returned
to the hospital in an ambulance.
Medical experts for Mr. R testified that there is no
way that a competent abdominal examination would
not have detected such a huge aneurysm. The ER
physician even testified that he would expect to be
able to feel something that large upon physical ex-
amination. Paramedics detected the same aneurysm
that the defendant physicians failed to detect. Ex-
perts for the defense failed to of fer any explanation
as to why an aneurysm of such proportions went
undetected in a man with a 35-inch waist. After hav-
ing the original chart of the family doctor examined
by a documents Continued on page nine.
7 OF COUNSEL NEWSLETTER VOLUME 05 NUMBER 3SEARCY DENNEY SCAROLA BARNHART & SHIPLEY, PA
IGNORINGCRITICAL MEDICALINFORMATION RESULTSIN WRONGFUL DEATH
$1.75 MillionSettlement:
O
“Experts for thedefense failed to explain
why an aneurysmthe size of two softballs
in a man with a35 inch waist
went undetected.”
8 OF COUNSEL NEWSLETTER VOLUME 05 NUMBER 3
“These attorneys arepart of the top 1.7%
of the 56,513Florida Bar members who
practice in the state.”
Chris Searcy
Greg Barnhart
David Sales
Darryl Lewis
Florida Trend business magazine, in its
second annual edition of ‘Florida Legal
Elite’, has chosen four members of
Searcy Denney Scarola Barnhart &
Shipley as being in the top 1.7% of
attorneys practicing in Florida. This
prestigious group is described by the
magazine as lawyers who have earned
the trust and confidence of those who
know their work the best. ■
The Meeting Corner:
Vincent L. Leonard, Jr.Vincent L. Leonard, Jr. grew up in Hicksville, New
York, the youngest of six children. In the late
1970’s, his family moved to Stuart, Florida, where
he graduated from Martin County High School.
Mr. Leonard attended the University of Florida
and Florida Atlantic University, earning a Bachelor
of Business Administration - Finance in 1985.
Mr. Leonard has over 20 years experience in the fi-
nance and insurance industry. He has extensive expe-
rience in the most complex issues of insurance
claims, coverage, liability, and damage analysis.
While employed with Allstate Insurance Company as
Florida’s litigation process expert, he provided lead-
ership on litigation protocols and management. Mr.
Leonard was the lead process expert in training and
management of Allstate’s compliance process relat-
ing to extra contractual liability and related laws. In
2003, Mr. Leonard accepted a temporary assignment
for Allstate’s home office to work on a development
project in Chicago, Illinois. During that assignment,
he gained extensive experience in the corporate legal
environment of the insurance industry. His duties on
that assignment included leadership and project man-
agement, technology, finance, product development
and marketing, and customer service.
Since joining the firm of Searcy Denney Scarola
Barnhart & Shipley in February, 2005, Mr. Leonard
has worked as a paralegal/investigator with attorney
Karen Terry. As part of Ms. Terry’s team, he utilizes
his particular skills and experience in various areas
of the firm’s practice, particularly including cases of
personal injury, medical malpractice, automobile
negligence, and related matters.
Mr. Leonard is a member of the Academy of Florida
Trial Lawyers and the Palm Beach County Trial Law-
yers Association. Mr. Leonard and his wife, Missy,
have been married 20 years. The Leonards and
their four children reside in Royal Palm Beach. ■
Four SDSBS Attorneys ListedIn Top 1.7% in Florida byFlorida Trend Magazine
Greg BarnhartGreg Barnhart spoke on “Voir Dire in
the Vehicular Crash Case” at the 2005
Voir Dire – Brain Storming with the
Masters Seminar hosted by the Acad-
emy of Florida Trial Lawyers, on April
7-8, 2005, in Orlando, Florida. ■
SEARCY DENNEY SCAROLA BARNHART & SHIPLEY, PA
Sia Baker-Barnes
Speaking Opportunities:
Chris Searcy spoke on “Prematurity”
to the Association of Trial Lawyers
of America, at the Birth Trauma
Litigation Group meeting held in
February 2005, at the Ritz-Carlton
in Atlanta, Georgia. ■
Harry Shevin
Chris Searcy
OF COUNSEL NEWSLETTER VOLUME 05 NUMBER 39
Sia Baker-Barnes has
been elected President of
the West Palm Beach
Chapter of The Links, Inc.
She will serve a two-year
term beginning in May.
The organization has more
than 11,000 members in 267 chapters covering
40 states, Germany, and the Bahamas. Its mis-
sion is to provide a “chain of friendship for its
members that includes a deep bond of purpose-
ful and committed public service”. ■
Harry Shevin chaired the Trauma for
Trial Lawyers II Seminar for the Palm
Beach County Trial Lawyers Associa-
tion. The seminar was held on May
13, 2005, in Palm Beach, Florida.
Mr. Shevin serves as Secretary of the
Association. ■
Accolades...
Sean C. Domnick was re-elected to
the Board and to the Executive
Committee of the Academy of
Florida Trial Lawyers. ■
Sean Domnick
Failure by Medical ExpertsTo Detect Massive AneurysmResults in DeathContinued from page seven.
expert, Lance Block and James Gustafson offered uncontestedproof that the family doctor destroyed the original record of Mr.
R’s office visit, and rewrote a fraudulent record after Mr. R died.
Plaintiff’s vascular surgery expert, a former director of thevascular surgery division of a major clinic (and an expert pro-
viding testimony in prior cases for all of the defense firms),
testified that Mr. R would have had a 90% chance of survival ifsurgery had been performed on him before he lapsed into
shock on the morning of June 5.
Alan R served his country in Vietnam, and upon returninghome, he continued to serve his country and fellow veterans
in the VA hospital system. He and his wife, Rita, worked to-
gether in the VA hospital system throughout the UnitedStates through 28 years of marriage. For over 20 years, they
drove to work, ate lunch, and drove home together every
day. They raised a daughter who lives in the same neighbor-hood, and were looking forward to enjoying retirement and
their new grandson when Alan’s life was cut short by sub-
standard medical care.
After extensive trial preparation, attorneys Lance Block
and James Gustafson of Searcy Denney Scarola Barnhart
and Shipley, negotiated a settlement in the amount of$1.75 million. ■
10 OF COUNSEL NEWSLETTER VOLUME 05 NUMBER 3SEARCY DENNEY SCAROLA BARNHART & SHIPLEY, PA
SDSBS Employees, Family and FriendsParticipate in Corporate 5K Run for Fitness
Taking...
On April 7, 2005, 29 SDSBS employees, with their friends and relatives, partici-
pated in the inaugural “Corporate 5K Run” in West Palm Beach. The Corporate
5K is an event organized to promote physical fitness and camaraderie by getting
team members out of the office and running or walking together. This was a
first-time event in West Palm Beach, drawing nearly 2,000 participants from
various local businesses. (The Corporate 5K has been held annually for the past
20 years in Miami and the past seven years in Ft. Lauderdale.) In addition to
helping employees become more physically active, the event provided an op-
portunity to donate funds to assist the Leukemia and Lymphoma Society in
its ef forts to find new treatments and cures.
Participants on the SDSBS Team were (pictured above): Earl
Denney, Karen Terry, Jack Hill, Laurie Briggs, Vivian Ayan-
Tejeda, Erica Lucas, Bobby Marques, Tom Peterson, Michelle
Peitz, Susan Gordon, Linda Miller, Janet Hernandez, Jas-
mine Thomas, Helene Walker, Lori Villario, Cheryl Phillips,
Phoebe Harris, Judy Lancaster, Angela Eckman, Robbie
Dunlap and Shirley Lucas. Also participating in the event
were Steve Smith, Pam Henney, Suzanne Valentage,
Connie Abel, Susan Hanlon, Ana Wright and Pam Roberts.
Kimberly Miller was the of ficial timekeeper for the team.
The team of Linda Miller, Phoebe Harris and Karen Terry
won First Place in the Women’s Legal Division.
As part of the event, businesses were also asked to provide
originally-designed t-shirts to be worn by team members during
the race and to enter the designs in the Corporate 5K T-Shirt Contest.
The SDSBS shirt (pictured here), was designed by Vincent Lucas (brother
of employee/participant Erica Lucas). Vincent’s design won First Place as the
“Most Original Design” in the race. ■
OF COUNSEL NEWSLETTER VOLUME 05 NUMBER 311
Celebration BenefitsBig Bend Cares Organization
In February, James and Josie Gustafson hosted “An Evening
with Friends” celebration to benefit Big Bend Cares, a non-
profit organization that provides education and comprehen-
sive support to people infected with, or af fected by,
HIV/AIDS. Big Bend Cares serves an eight-county area
in Florida’s Panhandle. It is the primary provider for
AIDS educational services in the mainly rural area. ■
4th Annual ‘Walk for the Animals’Benefits Animal Rescue LeagueIn March, SDSBS employees participated in the Fourth An-
nual Walk for the Animals. The event, hosted by Peggy
Adams Animal Rescue League, was held at Okeeheelee
Park. Participants raised $123,000 for the League’s low-
cost veterinary spay/neuter clinic in Palm Beach County. ■
SDSBS Hosts ReceptionHonoring GuatemalanNobel Peace Prize Winner
(l-r) Bill King, Jack Hill, Rigoberta
Menchu Tum, and Jack Scarola‘
International Academyof Trial LawyersChina ProgramChris Searcy serves as Secretary of the International
Relations Committee of the International Academy of
Trial Lawyers (IATL). IATL sends lawyers to Asia and
Eastern Europe to promote the rule of law in develop-
ing countries. The IRC sponsors trial lawyers from
these countries for membership in IATL. Photos taken
at a recent meeting in Hawaii. ■
On June 18, 2005 SDSBS hosted a reception honoring the
1992 Nobel Peace Prize Winner and historic representa-
tive of the Indigenous Maya People, Rigoberta Menchú
Tum. Ms. Menchú Tum was visiting West Palm Beach
through the invitation of Ana Maria de Monteagudo, the
Consul General of Guatemala. ■
(l-r) Randy Kriberney, Robin Kriberney, dog Bali,
Marilyn Hoffman and Britni Smith
$1.58 Billion VerdictAgainst Morgan Stanley
In this issue:
Failure to Provide ProperMedical Evaluation ResultsIn $7.5 Million Settlement
Page one.
Page five.
Page eight.
Attorney Bill Norton and paralegal Pete Love will join
attorneys Lance Block and James Gustafson in our firm’s
Tallahassee of fice. Mr. Norton is a shareholder with
SDSBS, and Mr. Love has worked with Mr. Norton at the
firm for 15 years. The office is located in the beautiful
and historic Towle House at 517 North Calhoun Street.
(Telephone 850-224-7600) ■
Bill Norton and Pete Love JoinSDSBS Office in Tallahassee
Four SDSBS AttorneysListed in Top 1.7% in Florida
PRSRT STD
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P. O. DRAWER 3626WEST PALM BEACHFLORIDA 33402-3626
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Volume 05, No. 3
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~ ....ttorneys::--_t- _at Law
SDSBS Teams Up ToWZn Landmark VictoryPerelman: $1.58 BillionMorgan Stanley: 0
On May 18, 2005, a jury in West Palm Beach, Florida delivered an historic judgment
against Morgan Stanley &... Co. on behalf of financier Ronald O. Perelman's company,
Coleman (Parent) Holdings, Inc. The jury found the investment banking firm liable for
its role in a fraud relating to the 1998 sale of The Coleman Company. the well-known
camping gear manufacturer, to Sunbeam Corporation, known for Its production of small
household appliances. The award (for compensatory and punitive damages) totaled
almost $1.45 billion. This is reportedly the largest judgment ever returned in the U.s.
for the benefit of a single individual. The case was marked by the defendant's extra
ordinary efforts to evade its court-ordered obligations to produce evidence, and its
accusations of Improper conduct against everyone from the judge to its own lawyers.
It was a David vs. Goliath battle between one of the nation's most astute investors,
Mr. Perelman, and a group of equally astute investment bankers. Mr. Perelman's
David, however, had the determination, the resources, and the highly-skilled legal
team necessary to pursue Morgan's Goliath to a spectacular decision. He also had the
great fortune of haVing the battle take place before Palm Beach County Circuit Court
Judge Elizabeth T. Maass, an extremely competent jurist who found herself and the
integrity of the legal system challenged by Morgan's aggressive behavior at every turn.
Mr. Perelman charged that the investment firm had participated In a massive fraud
involving the 1998 sale of Coleman to Sunbeam. In December, 1997, Mr. Perelman,
who owned controlling interest in Coleman (with 82% of its stock) was approached by
Sunbeam's new chief executive. Mr. Albert ("Chainsaw AI") Dunlap, with an offer to
buy Coleman. Discussions went poorly and the two men parted with-out agreement.
Shortly thereafter, Morgan re-initiated contact with Mr. Perelman on behalf of
Sunbeam, and negotiated a deal for the sale of Coleman to Sunbeam. Morgan had
brokered the first of many deals with Mr. Perelman 20 years ago, and Mr. Perelman
felt confident in working directly with Morgan. The sale, completed in March 1998,
was calculated to net Mr. Perelman about $1.5 billion, $680 million of which was
in Sunbeam stock. As Sunbeam's exclusive investment banker, Morgan earned a
$10 million fee on completing the deal.
just weeks after the deal closed, the market value of Mr.
Perelman's Sunbeam holdings began to evaporate.
Newly published sales and earnings figures dramatically
conflicted with earlier Sunbeam statements that had
been backed·up by Morgan. The revelations led to the
ouster of Sunbeam CE.O Dunlap, and then Its accountant,
Arthur Andersen, withdrew an audit of the company's
books. The Securities and Exchange Commission (SEC)
later charged Mr. Dunlap with fraud In "cooking the
books" of Sunbeam to create an illusion of financlal
success brought about by his leadership, when, in fact,
the company was in deep financial trouble. Mr. Dunlap
was later fined by the SEC and barred for life from
running any public company because of the fraud he had
conducted at Sunbeam. In 2001, after efforts to save the
doomed company failed, Sunbeam filed for bankruptcy
and all of Sunbeam's shareholders, including Mr,
Perelman, were left holding worthless stock. Unable to
seek meaningful compensation from bankrupt Sunbeam,
Mr. Perelman focused on Andersen's role in contributing
to Sunbeam's demise.
During the course of the Andersen litigation, Mr. Perel
man's legal team discovered a letter dated just days
before the Coleman-Sunbeam deal was to close. That
letter from Andersen to Morgan Stanley was delivered
to Morgan, as the bank also prepared to close Sun
beam's $750 million bond offering needed to finance
the Coleman deal. The letter outlined serious financial
troubles at Sunbeam, including decreasing sales, es
calating debts, and accumulating losses. Rather than
face the loss of tens of millions of dollars in transaction
fees, Morgan Stanley made the decision to help conceal
Sunbeam's true condition. A press release drafted with
Morgan's cooperation and issued by Sunbeam with
Morgan's approval continued to paint a grossly mis
leading picture of Sunbeam's economic performance.
Other documents prepared by Morgan for Sunbeam's
bond offering further misrepresented Sunbeam's
financial condition, enabling Morgan to attract enough
other deceived investors to earn a $22.5 million fee for
its work on that offering. A weel( after the offering
closed, Sunbeam acknowledged that its sales would fall
dramatically short of earlier estimates. Three years later,
Sunbeam filed for bankruptcy.
Morgan Stanley argued that it had accurately reported all
of the information available to it at the time, and that it,
too, was being lied to by Sunbeam. Mr. Perelman's
position was that Morgan not only knew of the financial
difficulties behind the scenes, but had a hand in preparing
documents that concealed the financial ill health of
Sunbeam, and had a duty to make accurate disclosures
to Mr. Perelman even though Morgan sat on the opposite
side of the negotiating table. In May 2003, after months
of investigation, argument, and fruitless negotiating
efforts between the parties, Mr. Perelman sued.
Legendary litigator Jerold Solovy, the highly-respected
Chairman of the 400-plus lawyer Chicago-based firm,
jenner &... Block, was chosen as the primary architect of
Mr. Perelman's trial strategy. Mr. Solovy had successfully
partnered with jack Scarola of Searcy Denney Scarola
Barnhart &... Shipley to secure a $70 million settlement
on behalf of Mr. Perelman against Arthur Andersen.
When the battle lines formed with Morgan Stanley,
Mr. Perelman and Mr, Solovy naturally turned once
again to Searcy Denney Scarola Barnhart &... Shipley
and Jack Scarola to round out the trial team.
SEARCY DENNEY SCAROLA BARNHART &. SHirLEY, r A., ATTORNEYS AT LAW2139 PALM BEACH LAKES BLVD.. WEST PALM BEACH. FL33409' 601:>-180-8607 • THE TO'NLE HOUSE, 517 NO. CALHOUN ST., TALLAHASSEE. FL32301 • 888·549-7011 • WWW.SEARCYLAW.COM
Jack Scarola
From the very beginning and throughout the trial, counsel
for the defendant battled aggressively with the plaintiff,
plaintiffs counsel, and the judge. During discovery before
the trial, Morgan engaged in protracted, deliberate and
concerted efforts to delay and obstruct the litigation by
failing to produce e-mail and other documents demanded
by the plaintiff and ordered to be produced by the court;
by destruction of evidence; by representing that docu~
ments had been destroyed when it knew back-up and
archived data existed; by concealing the fact that its lead
banker on the merger was being criminally prosecuted for
complicity in bribery at the very time he was representing
Morgan on the merger; and by
falsely certifying to plaintiff and
the court that it had searched for,
located and disclosed documents.
Confronted with compelling and
largely unrefuted evidence of
Morgan Stanley's misconduct,
Judge Maass responded at several
critical junctures in the trial with
tempered restraint. At each step,
she opted for carefully measured,
minimal sanctions against Morgan
expressly directed at correcting
the imbalances created by the
misconduct rather than punish
ment. Morgan's response was
to continue to evade court orders
and to openly charge the judge
with bias and emotionalism. As
Morgan's conduct continued
unabated, the Court was compelled to escalate the level
of sanctions imposed against Morgan in an effort to
alleviate the harm done to the plaintiff by Morgan's
repeated and intentional violation of court orders.
In March 2005, shortly before the trial began and
following days of evidentiary hearings, Judge Maass
concluded that the abuses by Morgan during discovery
had come to "infect the entire case", and she announced
her intention to issue a partial default order, directing
the jury to accept as established fact that Morgan had
conspired with and assisted Sunbeam in perpetrating a
fraud. Morgan had forfeited its right to defend itself only
on those issues directly related to the evidence that
Morgan had destroyed or concealed. The court stopped
significantly short of the full relief available under
Florida's procedural rules and well-established case
law. In an obvious effort to buy more time and divert
attention from its own misconduct, Morgan notified
the jUdge that it intended to fire its own lead counsel
that very day, without notice - and asked for a six
month continuance to find new counsel. Noting that
two other law firms had been actively defending Mor
gan for months, the judge denied the request.
As the Court summarized its findings, "ID]iscovery abuses
and misrepresentations by Morgan Stanley would
take a volume to recite Morgan
Stanley has deliberately and con
tumaciously violated numerous
discovery orders ... it chose to
hide information about its violations
and coach witnesses to avoid any
mention of additional, undisclosed
problems.... the prejudice to [Mr.
Perelman and Coleman (Parent)
Holdings, Inc.] from these failings
cannot be cured ... " The jUry was
instructed to accept as fact that the
investment bank participated in a
scheme to mislead Mr. Perelman
and to cover up its involvement in
Sunbeam's fraud on Mr. Perelman.
Considering Morgan's relentless
assault on the integrity of the judicial
system, and its persistent and serious
abuses, the trial court's measured
response was not only justified but essential. However,
the court's order left significant issues open for trial and
Morgan had plenty of fight and virtually limitless re
sources left to continue its relentless defense. At this
point, the plaintiff no longer had the burden to show that
fraudulent behavior had occurred, but only to show that
Mr. Perelman had relied on the Sunbeam/Morgan Stanley
lies and had suffered damage as a result of that reliance.
While important battles had clearly been won, the war
was hardly over. Proving that Ronald Perelman, a hugely
successful investor, with a large and sophisticated team
of business advisors of his own, placed any reliance on
Sunbeam and Morgan's statements in deciding to enter
SEARCY DENNEY SCAROLA BARNHART &. SHIPLEY, P A., ATTORNEYS AT LAW2139 PALM BEACH lAKES BLVD., WEST PALM BEACH. FL 33409 • 800-7BO·8B07 • THE TOWLE HOUSE, 517 NO. CALHOUN ST.• TALlAHASSEE. FL J2301 • 888·549·7011 • WINW.sEARCYLAW.COM
into a $1.5 billion deal would prove to be a daunting task.
Mr. Scarola spent four hours in opening statement to lay
the complex foundation for the case, which took almost
two months to try despite the fact that the issues had
been substantially narrowed.
Morgan's next response was an attempt to have judge
Maass removed from the case, argUing that her "bias, an
tagonism, and hostility" toward the company undermined
the integrity of the court and the ability of the defendant to
obtain a fair trial. Morgan's motion was denied twice - first
by Judge Maass herself and then by the appellate court,
which acted in support of JUdge Maass with extraordinary
swiftness. The appeal was denied within hours of the appel
late court's receipt of Morgan's papers. Morgan then sought
a mistrial by alleging jUry tampering, one of dozens of unsuc
cessful mistrial motions that peppered the trial proceedings.
Morgan completely underestimated the judge's determin
ation to conduct a fair and eqUitable trial, and the jUry's
ability to comprehend the massive scope and complexity of
Morgan's fraud. On May 16, the jUry awarded Mr. Perelman
$604 million in compensatory damages for haVing relied
on Morgan's misrepresentations about Sunbeam's finances.
The second phase, to determine both entitlement and
amount of punitive damages, started immediately.
Two days later, the jury awarded Mr. Perelman $850
million in punitive damages. The two jury awards totaled
$1.45 billion. On June 23rd, the trial judge added interest
owed by Morgan Stanley to Mr. Perelman. The judgment
now totals $1.5S billion. That amount sends a message to
businesses like Morgan Stanley that transparency is the
order of the day, that honesty is essential in business
transactions and In litigation, and that deception will not
be tolerated. Morgan said it plans to appeal the verdict.
jack Scarola stated in an interview follOWing the trial that
Judge Maass is an extremely bright, scrupulously fair, and
well-respected judge who is very rarely reversed at the
appellate level. She carefully documented the basis of
every one of her rUlings and acted well within the bounds
of established precedent. "We are extremely confident
that this is a record that is going to withstand the most
rigorous appellate review," Scarola said.
The after-shocks of the verdict are significant. lawyers
representing Mr. Perelman's company, Coleman (parent)
Holdings, Inc., intend to pursue contempt sanctions
against Morgan, including millions of dollars in attorneys'
fees and costs expended in establishing the bank's willful
violation of court orders. Mr. Perelman's counsel has
received numerous inquiries from lawyers throughout the
United States seeking information on behalf of their
clients who are investors with serious questions of their
own regarding Morgan Stanley's business practices.
Federal regulatory and enforcement agencies have
focused attention on the disclosures made in this case
concerning Morgan Stanley's activities. Morgan's stock
price has reacted to the bad news, and its current CEO,
Phillp Purcell, recently announced his resignation
FollOWing the earlier departure of numerous high
ranl<ing Morgan Stanley executives. The very future
of Morgan Stanley, a Wall Street giant, is in question.
Morgan's Goliath may not be dead, but Ronald Perelman
has certainly brought this Goliath to its Imees.•
SEARCYDENNEY
SCAROLABARNHART8-- SHIPLEY PA
-Attornl!JlS__at Law
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Accounts of recent tr/d/s, verdicts dnd settlements Me intended
to i/lustrdte the experience of the firm in d vdriety of litigation
dreas. Edch Cdse is unique, dnd the results in one Cdse do not
necessarily indicdte the qUdlfty or vdJue of dny other Cdse.
Recommended